Skip to Content

NAIC’s Third-Party Data and Model Vendors Regulatory Framework Strikes Some Sour Notes
January 12, 2026

The National Association of Insurance Commissioners’ (NAIC) Third-Party Data and Models (H) Working Group issued a preview of its breakout single: a proposed risk-based regulatory framework for third-party data and model vendors. While stressing that insurers are still responsible for carrying the accountability tune, the draft
framework’s melody focuses on ensuring regulatory oversight of such vendors, particularly with respect to insurance functions with direct consumer impact.

The proposal, however, is likely to strike some sour notes, including:

  • Vendor registration
  • Annual attestations
  • Regulatory access requirements
  • Material change notifications
  • State-specific, discretionary model filings and reviews

The group is accepting comments until February 6, and there is much unsung. What harmonies will be struck, what tempo the process will take, and how much of this proposal will remain on the studio floor remain to be seen.
Authored By
Image: Ann Young Black
Ann Young Black
Image: Patricia M. Carreiro
Patricia M. Carreiro
Related Practices
Financial Services Regulatory
Related Industries
Life, Annuity, and Retirement Solutions
©2026 Carlton Fields, P.A. Carlton Fields practices law in California through Carlton Fields, LLP. Carlton Fields publications should not be construed as legal advice on any specific facts or circumstances. The contents are intended for general information and educational purposes only, and should not be relied on as if it were advice about a particular fact situation. The distribution of this publication is not intended to create, and receipt of it does not constitute, an attorney-client relationship with Carlton Fields. This publication may not be quoted or referred to in any other publication or proceeding without the prior written consent of the firm, to be given or withheld at our discretion. To request reprint permission for any of our publications, please use our Contact Us form via the link below. The views set forth herein are the personal views of the author and do not necessarily reflect those of the firm. This site may contain hypertext links to information created and maintained by other entities. Carlton Fields does not control or guarantee the accuracy or completeness of this outside information, nor is the inclusion of a link to be intended as an endorsement of those outside sites.

Disclaimer

The information on this website is presented as a service for our clients and Internet users and is not intended to be legal advice, nor should you consider it as such. Although we welcome your inquiries, please keep in mind that merely contacting us will not establish an attorney-client relationship between us. Consequently, you should not convey any confidential information to us until a formal attorney-client relationship has been established. Please remember that electronic correspondence on the internet is not secure and that you should not include sensitive or confidential information in messages. With that in mind, we look forward to hearing from you.